Manhattan Club Lawsuit

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Original Message:

Re: Manhattan Club Lawsuit (by Vivien S.):

On August 5, lawyers representing TMC developers filed a motion to release funds to pay for their legal expenses. Maybe we should all write to Judge Rakower and ask her to block this motion. TMC is still under investigation for possible fraud and financial mismanagement.

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ----------------------------------------------------------------------x In the Matter of an Inquiry by ERIC T. SCHNEIDERMAN, Attorney General of the State of New York, Petitioner-Appellee, Pursuant to Article 23-A of the New York General Index No. 451536/2014 Business Law in regard to the acts and practices of (Rakower, J.) IAN BRUCE EICHNER, LESLIE H. EICHNER, STUART P. EICHNER, SCOTT L. LAGER T. PARK CENTRAL LLC, O. PARK CENTRAL LLC, NOTICE OF MOTION PARK CENTRAL MANAGEMENT LLC, TO RELEASE FUNDS MANHATTAN CLUB MARKETING GROUP LLC, and NEW YORK URBAN OWNERSHIP MANAGEMENT LLC, Motion Seq. 005 Respondent-Appellants, in promoting the issuance, distribution, exchange, advertisement, negotiation, purchase, investment advice or sale of securities in or from New York State. ----------------------------------------------------------------------x PLEASE TAKE NOTICE THAT, upon the Affirmation of Chester Zimmerman, dated August 5, 2016 and the exhibits annexed thereto, and the Memorandum of Law, Respondents T. Park Central LLC, O. Park Central LLC, Park Central Management LLC, The Manhattan Club Marketing Group LLC, and New York Urban Ownership Management LLC (collectively, the “Respondent Entities”) hereby move this Court on August 29, 2016 at the Motion Submission Part Courtroom, Room 130, at 9:30 AM, in the New York County Courthouse, located at 60 Centre Street, New York, New York, for an Order releasing frozen funds for the purpose of paying ongoing legal fees related to this matter this matter and two other lawsuits in which the Respondent Entities are defendants and related legal matters. FILED: NEW YORK COUNTY CLERK 08/05/2016 06:21 PM INDEX NO. 451536/2014 NYSCEF DOC. NO. 367 RECEIVED NYSCEF: 08/05/2016

PLEASE TAKE FURTHER NOTICE THAT, as agreed to by the parties, opposition papers will be served August 12, 2016, and reply papers will be served August 26, 2016. Dated: August 5, 2016 Respectfully submitted, WINSTON & STRAWN LLP By: /s/ Kelly A. Librera____ Gerald L. Shargel Kelly A. Librera Evan Lipton Anna Lamut Winston & Strawn LLP 200 Park Avenue New York, New York 10166 (212) 294-4622 Attorneys for Respondents Ian Bruce Eichner Leslie H. Eichner Stuart P. Eichner T. Park Central LLC O. Park Central LLC Park Central Management Manhattan Club Marketing Group LLC New York Urban Ownership Management LLC